Dismissing the appeal the Court held that  the condition precedent of recording the requisite satisfaction which is a safeguard provided in S. 14A should not be overlooked before applying rule 8D . The contention of the Department that once there were mixed funds, i. e., interest free as well as interest bearing funds with the assessee, rule 8D would be attracted automatically could not be accepted.  Order of Tribunal is affirmed .(AY. 2010-11)